20240304Application.pdf

NELS ON MULLINS RILEY & SCARB OR OU GH LLP
ATTORNEYS AN D C OUNS ELORS AT LAW

101 Const it uti on Av e, NW, S uit e 900
Was hi ngton, DC 20001
T: 202.689. 2800 F: 202.689.2860
nelsonmullins.com

CAL I F O RN I A | CO L O R A D O | DI S T R I CT O F CO L U M BI A | FL O R I D A | GE O R G I A | IL L I N O I S | MA R Y L A ND | MA S S A C H US E T T S | MI N N E S O T A
NE W YO RK | NO RT H CA RO L I NA | OHI O | PE N NS Y L V AN I A | SO U T H CAR O L I N A | TE NN E S S E E | TE X A S | VI RG I N I A | WE S T VI RG I NI A
Debra Mc Gui re Merc er
T: 202.689.2949
[e-mail]
March 4, 2024
Via Email
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Building 8 Suite 201-A
Boise, ID 83714
[e-mail]

RE: TruConnect Communications, Inc. Application for Designation as an Eligible
Telecommunications Carrier in the State of Idaho for the Limited Purpose of
Offering Lifeline Service
Dear Secretary Noriyuki :
Attached please find TruConnect Communications, Inc.’s Application for Designation as
an Eligible Telecommunications Carrier in the State of Idaho. Should you have any questions,
please contact the undersigned.

Respectfully submitted,
Debra McGuire Mercer
Counsel for TruConnect Communications, Inc.

RECEIVED
Monday, March 4, 2024 3:23:23 PM
IDAHO PUBLIC
UTILITIES COMMISSION
CASE NO. TCC-T-24-01

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION

TruConnect Communications, Inc.

Application for Designation as an
Eligible Telecommunications Carrier
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)
)
)
)

Docket No. __________

APPLICATION OF TRUCONNECT COMMUNCIATIONS, INC.
FOR DESIGNATION AS AN ELIGIBLE TELECOMMUNICATIONS CARRIER
IN THE STATE OF IDAHO

Debra McGuire Mercer
Michael J. Nemcik
Nelson Mullins Riley & Scarborough LLP
101 Constitution Avenue, NW
Suite 900
Washington, DC 20001
[phone]
[e-mail]

Counsel for TruConnect Communications, Inc.

March 4, 2024

TABLE OF CONTENTS
I. INTRODUCTION ...............................................................................................................1
II. COMPANY OVERVIEW ....................................................................................................3
III. THE COMMISSION HAS JURISDICTION OVER DESIGNATION OF WIRELESS
ETCS ....................................................................................................................................5
IV. TRUCONNECT SATISFIES THE REQUIREMENTS FOR DESIGNATION AS AN ETC
UNDER 47 C.F.R. § 54.201 ................................................................................................7
V. TRUCONNECT SATISFIES THE ADDITIONAL REQUIREMENTS FOR ETC
DESIGNATION UNDER 47 C.F.R. § 54.202(a) ..............................................................13
VI. DESIGNATION OF TRUCONNECT AS AN ETC WOULD PROMOTE THE PUBLIC
INTEREST .........................................................................................................................20
VII. CONCLUSION ..................................................................................................................24

TABLE OF EXHIBITS

Certification 1

FCC-Approved Compliance Plan

2
Coverage Area

3
Sample Advertisements

4
Key Management Bios 5
Proposed Lifeline Offering

6

1
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION

TruConnect Communications, Inc.

Application for Designation as an
Eligible Telecommunications Carrier
)
)
)
)
)

Docket No. __________

I. INTRODUCTION
TruConnect Communications, Inc. (“TruConnect” or the “Company”), pursuant to
Section 214(e)(2) of the Communications Act of 1934, as amended (the “Act”),1 Sections 54.101
through 54.207 of the Rules of the Federal Communications Commission (“FCC”),2 the Idaho
Telecommunications Act of 1988,3 and the orders of the Idaho Public Utilities Commission
(“Commission”),4 hereby submits this Application for Designation as an Eligible
Telecommunications Carrier (“ETC”) in the State of Idaho (“Application”).
TruConnect seeks ETC designation solely to provide Lifeline service to qualifying Idaho
consumers; it will not (and is not eligible to) seek access to funds from the federal Universal
Service Fund (“USF”) for the purpose of participating in the Link-Up program or providing

1 47 U.S.C. § 214(e)(2)
2 47 C.F.R. §§ 54.101-54.207.
3 Idaho Code §§ 62-610D and 62-615(1).
4 Application of WWC Holding Co., Inc. dba Cellular-One® Seeking Designation as an Eligible
Telecommunications Carrier That May Receive Federal Universal Service Support, Case No.
WST-T-05-1, Order No. 29841(Aug. 4, 2005) (attaching Appendix titled “Requirements for
Eligible Telecommunications Carrier (“ETC”) Designation, Reporting, and Certification”)
(“Order No. 29841”), as amended by Torch Wireless’s Application for Designation as an Eligible
Telecommunications Carrier in Idaho, Case No. TOR-21-01, Order No. 35126 (Aug. 25, 2021)
(removing requirement that the Commission (in addition to the applicant) provide notice of an
ETC application to affected Tribes) (“Order No. 35126”).
2
service to high cost areas.5 TruConnect requests for its ETC designation to include the authority
to participate in and receive reimbursement from the Idaho Telephone Service Assistance
Program (“ITSAP”).6
As demonstrated herein, and as certified in Exhibit 1 attached hereto, TruConnect meets
all the statutory and regulatory requirements for designation as an ETC in the State of Idaho,
including the requirements outlined in the FCC’s Lifeline and Link Up Reform Order,7 Lifeline
Modernization Order,8 and Fifth Report and Order.9 Furthermore, TruConnect is positioned to
reach unserved and underserved Lifeline-eligible consumers. Rapid grant of TruConnect’s
request, therefore, would advance the public interest because it would enable the Company to
commence much needed Lifeline services to a wide array of low-income Idaho residents as soon
as possible. Accordingly, the Company respectfully requests that the Commission expeditiously
approve this Application.

5 Given that the Company only seeks Lifeline support from the low-income program and does
not seek any high-cost support, ETC certification requirements for the high-cost program are not
applicable to the Company.
6 Idaho Code §§ 56-901, 56-902.
7 Lifeline and Link Up Reform and Modernization, Lifeline and Link Up, Federal-State Joint
Board on Universal Service, Advancing Broadband Availability Through Digital Literacy
Training, WC Docket No. 11-42, WC Docket No. 03-109, CC Docket No. 96-45, WC Docket
No. 12-23, Report and Order and Further Notice of Proposed Rulemaking, FCC 12-11 (rel. Feb.
6, 2012) (“Lifeline and Link Up Reform Order”).
8 Lifeline and Link Up Reform and Modernization, Telecommunications Carriers Eligible for
Universal Service Support, Connect America Fund, WC Docket No. 11-42, WC Docket No. 09-
197, WC Docket No. 10-90, Third Report and Order, Further Report and Order, and Order on
Reconsideration, FCC 16-38 (rel. Apr. 27, 2016) (“Lifeline Modernization Order”).
9 Bridging the Digital Divide for Low-Income Consumers, Lifeline and Link Up Reform and
Modernization, Telecommunications Carriers Eligible for Universal Service Support, WC
Docket No. 17-287, WC Docket No. 11-42, WC Docket No. 09-197, Fifth Report and Order,
Memorandum Opinion and Order and Order on Reconsideration, and Further Notice of Proposed
Rulemaking, FCC 19-111 (rel. Nov. 14, 2019) (“Fifth Report and Order”).
3
All correspondence, communications, pleadings, notices, orders and decisions relating to
this Application should be addressed to:
Nathan Johnson
Co-CEO
TruConnect Communications, Inc.
1149 South Hill Street, Suite H-400
Los Angeles, CA 90015
Phone: [phone]
[e-mail]
and
Danielle Perry
Chief Compliance Officer
TruConnect Communications, Inc.
1149 South Hill Street, Suite H-400
Los Angeles, CA 90015
Phone: [phone]
[e-mail]

II. COMPANY OVERVIEW
TruConnect is a Delaware corporation with its principal office located at 1149 S. Hill
Street, Suite H-400, Los Angeles, California 90015. TruConnect is authorized to do business in
Idaho. TruConnect Communications, Inc., formerly Telscape Communications, Inc., is a
subsidiary of TSC Acquisition Corporation (“TSC”). TSC also owns Sage Telecom
Communications, LLC d/b/a TruConnect (“Sage d/b/a TruConnect”), formerly known as Sage
Telecom, Inc. before a corporate restructuring in 2012. The owners of TSC separately own
TruConnect Mobile, LLC, which sells mobile hotspot devices and low-cost monthly data plans,
as well as TruConnect Technologies, LLC, a mobile data analytics company that develops data
intelligence products and services for wireless carriers, cable operators, and content providers.
TruConnect provides prepaid wireless telecommunications services to consumers by
using the underlying wireless networks of facilities-based providers, T-Mobile USA, Inc. (“T-
Mobile”) and Verizon Wireless (“Verizon”) (collectively, “Underlying Carriers”) on a wholesale
4
basis to offer nationwide service. TruConnect is currently designated and operating as a wireless
ETC in California, New Jersey, Massachusetts, Rhode Island, Vermont, Tennessee, Virginia, and
the U.S. Virgin Islands. TruConnect is also authorized by the FCC and the Universal Service
Administrative Company (“USAC”) to participate in the Affordable Connectivity Program
(“ACP”) throughout the United States, including Idaho.
TruConnect’s prepaid wireless services are affordable, easy to use, and attractive to low-
income consumers, providing them with access to emergency services and a reliable means of
communication that can be used both at home and while traveling to remain in touch with friends
and family and for contacting prospective employers. TruConnect offers consumers simple and
affordable prepaid calling plans, easy-to-use handsets, and high-quality customer service. Given
its pricing and marketing strategy and the demographics of its customers in other states,
TruConnect anticipates that many of its customers will be from low-income backgrounds who
have not previously enjoyed access to wireless service because of economic constraints, poor
credit history, or sporadic employment. TruConnect does not conduct credit checks or require
customers to enter into long-term service contracts as a prerequisite to obtaining wireless service.
By providing affordable wireless plans and quality customer service to consumers who
are otherwise unable to afford them, or who were previously ignored by traditional carriers,
TruConnect will expand the availability of wireless services to many more consumers, which is
the principal reason for which Congress created the universal service program.
TruConnect’s service offering will include: (1) local and long-distance calling; (2) access
to the following custom calling features at no charge: (a) Caller ID; (b) Call Waiting; (c) Call
Forwarding; (d) 3-Way Calling; and (e) Voicemail; (3) text messaging; (4) broadband access; and
(5) the option for a consumer to “bring their own device”. TruConnect may provide user-
5
friendly handsets or hotspot devices. TruConnect’s products and plans will be specially geared
toward serving lower income communities, especially in rural areas that are predominantly
unserved by other ETCs designated in the state, and its service models and pricing plans will
reflect this mission. The Company will not require service contracts from its customers, and it
will always ensure competitively low pricing for its services and products. TruConnect will
manage all aspects of the customer experience, including setting service pricing, handset
selection, marketing materials, and live customer service. The Company’s prepaid, budget-
friendly pricing will give many low-income consumers the option of having mobile phone
service and broadband access without the burden of hidden costs, varying monthly charges, or
contractual commitments. Customers will be able to customize their TruConnect service to suit
their needs with available bundles of minutes and broadband data to supplement their monthly
plan.
TruConnect will affirmatively reach out to the low-income sector of the consumer base to
offer attractive and affordable communications options. As such, TruConnect will contribute to
the expansion of mobile wireless and broadband services for low-income consumers in Idaho.
III. THE COMMISSION HAS JURISDICTION OVER DESIGNATION OF
WIRELESS ETCS
Section 214(e)(2) of the Act provides state public utility commissions with the “primary
responsibility” for the designation of ETCs.10 Although Section 332(c)(3)(A) of the Act
prohibits states from regulating the entry of or the rates charged by any provider of commercial
mobile service or any private mobile service, this prohibition does not allow states to deny

10 47 U.S.C. § 214(e)(2).
6
wireless carriers ETC status.11 Under the Act, a state public utility commission with
jurisdictional authority over ETC designations must designate a common carrier as an ETC if the
carrier satisfies the requirements of Section 214(e)(1). As demonstrated in this Application,
TruConnect meets these requirements. TruConnect requests that the Commission expeditiously
process the instant Application so that TruConnect can quickly begin expanding the availability
of affordable Lifeline-supported wireless services to qualifying low-income customers in Idaho.
TruConnect recognizes that Section 214(e)(1)(A) of the Act states that ETCs shall offer
services, at least in part, over their own facilities and that Section 54.201(i) of the FCC’s Rules
(47 C.F.R. § 54.201(i)) prohibits state commissions from designating as an ETC a
telecommunications carrier that offers services exclusively through the resale of another carrier’s
services. However, the FCC has granted forbearance from enforcement of this facilities
requirement to carriers seeking Lifeline-only ETC designation.12 Section 10(e) of the Act (47
U.S.C. § 160(e)) provides: “[a] State commission may not continue to apply or enforce any
provision of this chapter that the [Federal Communications] Commission has determined to
forbear from applying under subsection (a) of this section.” As such, the Commission is required
by Section 10(e) to act in accordance with the FCC’s grant of forbearance, and therefore, may
not apply the facilities-based requirement to TruConnect. Therefore, the Commission has the
authority under Section 214(e)(2) of the Act to grant TruConnect’s request for designation as an
ETC throughout the State of Idaho.

11 See Federal-State Joint Board on Universal Service, Report and Order, 12 FCC Rcd 8776,
8858-59, ¶ 145 (1997) (“USF Order”).
12 See Lifeline and Link Up Reform Order, ¶ 368.
7
IV. TRUCONNECT SATISFIES THE REQUIREMENTS FOR DESIGNATION AS AN
ETC UNDER 47 C.F.R. § 54.201
Section 254(e) of the Act provides that, “only an eligible telecommunications carrier
designated under section 214(e) shall be eligible to receive specific federal universal service
support.” Section 214(e)(2) of the Act authorizes state commissions, such as the Commission, to
designate ETC status for federal universal service purposes and authorizes the Commission to
designate wireless ETCs.13 Section 214(e)(1) of the Act and Section 54.201(d) of the FCC’s
rules provide that applicants for ETC designation must be common carriers that shall, throughout
the designated service area, offer all of the services supported by universal service, either using
their own facilities or a combination of their own facilities and the resale of another carrier’s
services, except where the FCC has forborne from the “own facilities” requirement. Applicants
also must commit to advertise the availability and rates of such services.14 As detailed below,
TruConnect satisfies each of the above-listed requirements, as well as any other requirements for
ETC designation by the FCC pursuant to Section 214(e)(2) of the Communications Act and
Order No. 29841.15
The Commission also considers (1) whether the applicant will contribute to appropriate
Idaho funds, which include funds that support the ITSAP and the Idaho Telecommunications
Relay Services program,16 and (2) whether the applicant is engaged in “cream-skimming” (i.e.,

13 See USF Order, ¶ 145.
14 See 47 U.S.C. § 214(e)(1) and 47 C.F.R. § 54.201(d)(2).
15 Order No. 29841 provides: “All ETC applicants must follow the federal statutory requirements
for ETC Designation. See 47 U.S.C. § 214(e)(1).” Appendix, § A.
16 See Idaho Code §§ 56-904, 61-1301.
8
when an applicant seeks ETC designation for only part of a rural telephone company’s study
area, thus leaving some customers (who are likely less-profitable) without service).17
A. TruConnect Will Provide Service Consistent with the FCC’s Grant of
Forbearance from Section 214’s Facilities Requirements
Although Section 214 requires ETCs to provide services using their facilities, at least in
part, the FCC has forborne from that requirement with respect to carriers such as TruConnect. In
the Lifeline and Link Up Reform Order, the FCC granted forbearance from the “own-facilities”
requirement contained in Section 214(e)(1)(A) for carriers that are, or seek to become, Lifeline-
only ETCs, subject to the following conditions:18
(1) the carrier must comply with certain 911 requirements [(a) providing its Lifeline
subscribers with 911 and E911 access, regardless of activation status and availability of
minutes; (b) providing its Lifeline subscribers with E911-compliant handsets and
replacing, at no additional charge to the subscriber, noncompliant handsets of Lifeline-
eligible subscribers who obtain Lifeline-supported services; and (c) complying with
conditions (a) and (b) starting on the effective date of this Order]; and
(2) the carrier must file, and the Bureau must approve, a compliance plan providing specific
information regarding the carrier’s service offerings and outlining the measures the
carrier will take to implement the obligations contained in this Order as well as further
safeguards against waste, fraud and abuse the Bureau may deem necessary.
In accordance with the Lifeline and Link Up Reform Order, TruConnect filed a
Compliance Plan with the FCC, which the FCC approved on December 26, 2012,19 a copy of
which is attached hereto as Exhibit 2. TruConnect commits to providing Lifeline service in
Idaho in accordance with its FCC-approved Compliance Plan, as amended, and in compliance

17 See, e.g., Order No. 35126, at 5.
18 See Lifeline and Link Up Reform Order, ¶¶ 368, 373, and 379.
19 See Wireline Competition Bureau Approves the Compliance Plans of Airvoice Wireless,
Amerimex Communications, Blue Jay Wireless, Millennium 2000, Nexus Communications,
Platinumtel Communications, Sage Telecom, Telrite and Telscape Communications, WC Docket
No. 09-197, WC Docket No. 11-42, Public Notice, DA 12-2063 (Dec. 26, 2012). On April 10,
2023, TruConnect filed a letter with the FCC to advise that it had updated certain practices to
reflect current Lifeline rules. A copy of the letter is included in Exhibit 2.
9
with applicable state and federal regulations, to the extent amendments thereto may supersede
commitments made in the Compliance Plan.
B. TruConnect Is a Common Carrier
CMRS providers like TruConnect are treated as common carriers.20
C. TruConnect Will Provide All Supported Services
Through its Underlying Carriers, TruConnect is able to provide all of the supported
services required by Section 54.101(a) of the FCC’s Rules (47 C.F.R. § 54.101(a)) as follows:
1. Voice Telephony Service
As set forth in 47 C.F.R. § 54.101(a)(1), eligible Voice Telephony Services must provide
the following:
Voice Grade Access to the Public Switched Telephone Network. TruConnect provides
voice grade access to the public switched telephone network (“PSTN”) through the purchase of
wholesale CMRS services from T-Mobile and Verizon.
Local Usage At No Additional Charge. TruConnect offers rate plans that provide its
customers with minutes of use for local service at no additional charge.
Access to Emergency Services. TruConnect provides 911 and E911 access for all of its
customers to the extent the local government in its service area has implemented 911 or E911

20 Implementation of Sections 3(n) and 332 of the Communications Act, Regulatory Treatment of
Mobile Services, Second Report and Order, 9 FCC Rcd 1411, 1425 ¶ 37, 1454-55 ¶ 102 (1994)
(wireless resellers are included in the statutory “mobile services” category, and providers of
cellular service are common carriers and CMRS providers); 47 U.S.C. § 332(c)(1)(A) (“mobile
services” providers are common carriers); see also PCIA Petition for Forbearance for
Broadband Personal Communications Services et al., Memorandum Opinion and Order and
Notice of Proposed Rulemaking, 13 FCC Rcd 16857, 16911 ¶ 111 (1998) (“We concluded [in the
Second Report and Order] that CMRS also includes the following common carrier services:
cellular service, ... all mobile telephone services and resellers of such services.”) (emphasis
added).
10
systems. As noted, calls to 911 emergency services will always be free and will be available
regardless of service activation status or availability of minutes. TruConnect also complies with
the FCC’s regulations governing the deployment and availability of E911 compatible handsets.
Toll Limitation. In its Lifeline and Link Up Reform Order, the FCC provided that toll
limitation would no longer be deemed a supported service.21 “ETCs are not required to offer toll
limitation service to low-income consumers if the Lifeline offering provides a set amount of
minutes that do not distinguish between toll and non-toll calls.”22 Nonetheless, TruConnect’s
offerings inherently allow Lifeline subscribers to control their usage, as its wireless service is
offered on a prepaid, or pay-as-you-go, basis. TruConnect’s service, moreover, is not offered on
a distance-sensitive basis and local and domestic long-distance minutes are treated the same.
2. Broadband Internet Access Services
While no longer a required supported service under 47 C.F.R. § 54.101(a), TruConnect
provides Broadband Internet access service (“BIAS”) to ensure its Lifeline customers receive full
Lifeline support. The FCC has stated that BIAS consists of the ability for a user to receive “the
capability to transmit data to and receive data from all or substantially all Internet endpoints,
including any capabilities that are incidental to and enable the operation of the communications
service, but excluding dial-up Internet access service.”23 TruConnect provides BIAS to low-
income consumers via resale of T-Mobile and Verizon’s services.

21 See Lifeline and Link Up Reform Order, ¶ 367.
22 See id. ¶ 49.
23 See 47 C.F.R. § 8.1(b).
11
D. TruConnect Requests Designation Throughout Its Service Area
TruConnect is not a rural telephone company as defined in Section 3(44) of the Act (47
U.S.C. § 153(44)). Accordingly, TruConnect is required to describe the geographic area(s)
within which it requests designation as an ETC. TruConnect requests ETC designation that is
statewide in scope to allow the Company to provide Lifeline service wherever its underlying,
facilities-based providers have wireless coverage. TruConnect’s requested service area includes
the four federally recognized Tribal Lands located throughout the State of Idaho.24 The current
zip code coverage footprint is attached hereto as Exhibit 3. TruConnect understands that its
service area overlaps with rural carriers in Idaho but maintains that the public interest factors
described below justify its designation in these carriers’ service areas, especially because it seeks
ETC designation solely to utilize USF funding to provide Lifeline service to qualified low-
income consumers. TruConnect is not eligible for and does not seek Link-Up or high-cost
support.
Therefore, designation of TruConnect as an ETC will cause no growth in the high-cost
portions of the USF and will not erode high-cost support from any rural telephone company. In
fact, the FCC has determined that “[d]esignation of competitive ETCs promotes competition and
benefits consumers in rural and high-cost areas by increasing customer choice, innovative
services, and new technologies.”25 While federal rules (47 U.S.C. §§ 160, 214(e)(5) and 47
C.F.R. § 54.207(b)) require that the service area of an ETC conform to the service area of any
rural telephone company serving the same area (the “service area conformance” requirement),

24 In accordance with Order No. 29841, TruConnect is providing a copy of this Application to the
affected Tribal governments and Tribal regulatory authorities.
25 See Western Wireless Corporation Petition for Designation as an Eligible Telecommunications
Carrier in the State of Wyoming, Memorandum Opinion and Order, 16 FCC Rcd 48, 55 ¶ 7
(2000).
12
the FCC’s Lifeline and Link Up Reform Memorandum Opinion and Order (FCC 13-44 released
April 15, 2013) authorized forbearance from the service area conformance requirements with
respect to carriers seeking to provide Lifeline-only service.26 In light of this forbearance, the
Commission has the authority to designate ETCs such as TruConnect in rural areas without
concern for the service area conformance requirement.27
E. TruConnect Will Advertise the Availability of Supported Services
TruConnect will advertise the availability and rates for the services described above using
media of general distribution as required by 47 C.F.R. § 54.201(d)(2) and Idaho Code § 62-
610D(3)(b). TruConnect will comply with the FCC’s rules regarding information to be included
in marketing materials, including rule section 54.405(c). Specifically, TruConnect’s marketing
materials will state, in easily understood language, that: (i) the service is a Lifeline service; (ii)
Lifeline is a government assistance program; (iii) the service may not be transferred to someone
else; (iv) consumers must meet certain eligibility requirements before enrolling in the Lifeline
program; (v) the Lifeline program permits only one Lifeline discount per household; (vi)
documentation is necessary for enrollment; and (vii) TruConnect is the provider of the services.
Moreover, the Lifeline application/certification form will state that Lifeline is a federal benefit
and that consumers who willfully make a false statement in order to obtain the Lifeline benefit
can be punished by fine or imprisonment or can be barred from the program. Additionally,
TruConnect will disclose the company name under which it does business and the details of its

26 See Telecommunications Carriers Eligible for Support, Lifeline and Link Up Reform, WC
Docket No. 09-197, WC Docket No. 11-42, Memorandum Opinion and Order, FCC 13-44 (rel.
Apr. 15, 2013).
27 See 47 C.F.R. § 54.207(c).
13
Lifeline service offerings in any Lifeline-related marketing and advertising. Sample
advertisements that will be used in Idaho are attached hereto as Exhibit 4.
TruConnect will engage in advertising campaigns specifically targeted to reach those
likely to qualify for Lifeline service, promoting the availability of cost-effective wireless services
to this neglected consumer segment. TruConnect may also promote the availability of its
Lifeline offering by distributing brochures at various state and local social service agencies and
may partner with nonprofit assistance organizations to inform customers of the availability of its
Lifeline service. In addition, TruConnect intends to utilize its network of retail partners (once
established) to help promote the availability of its Lifeline plans, especially retail outlets that are
frequented by low-income consumers. TruConnect will provide retail vendors with signage to be
displayed where Company products are sold, and with printed materials describing the
Company’s Lifeline program.
V. TRUCONNECT SATISFIES THE ADDITIONAL REQUIREMENTS FOR ETC
DESIGNATION UNDER 47 C.F.R. § 54.202(a)
TruConnect hereby provides the additional information and certifications required for
carriers seeking ETC designation as set forth in 47 C.F.R. § 54.202(a).
A. Service Commitment Throughout the Proposed Designated Service Area
TruConnect will provide service in Idaho by reselling service which it obtains from its
Underlying Carriers. Both the T-Mobile and Verizon networks are operational and largely built
out. Thus, TruConnect will be able to commence offering its Lifeline service to all locations
served by T-Mobile and Verizon very soon after receiving approval from the Commission.
In accordance with 47 C.F.R. § 54.202(a)(1)(i), and by the certification attached in
Exhibit 1, TruConnect commits to comply with the service requirements applicable to the low-
income support that it receives, including the rules set forth in the FCC’s Fifth Report and Order.
14
Pursuant to 47 C.F.R. § 54.202(a)(1)(ii), a common carrier seeking designation as a Lifeline-only
ETC is not required to submit a five-year network improvement plan as part of its application for
designation as an ETC.
B. Ability to Remain Functional in Emergency Situations
In accordance with 47 C.F.R. § 54.202(a)(2), TruConnect has the ability to remain
functional in emergency situations. As discussed, TruConnect will utilize the extensive and well-
established network and facilities of T-Mobile and Verizon to provide its Lifeline services. The
Company understands that the networks of its Underlying Carriers have access to a reasonable
amount of back-up power to ensure functionality without an external power source, can reroute
traffic around damaged facilities, and are capable of managing traffic spikes resulting from
emergency situations. Indeed, the Underlying Carriers have certified to the FCC that their
networks function in emergency situations.28 The Underlying Carriers provide the same
functionality to TruConnect and its customers as they provide to themselves and their own
customers.
C. Commitment to Consumer Protection and Service Quality
In accordance with 47 C.F.R. § 54.202(a)(3), an ETC applicant must demonstrate that it
will satisfy applicable consumer protection and service quality standards, and wireless applicants
may satisfy this requirement with a commitment to comply with the Cellular
Telecommunications and Internet Association’s (“CTIA”) Consumer Code for Wireless Service.
TruConnect hereby commits to comply with the CTIA Consumer Code for Wireless Service.

28 See, e.g., Sprint Nextel Corporation Verified Filing in Compliance with 47 C.F.R. § 54.209, CC
Docket No. 96-45, at 6 (filed Sept. 30, 2011); Telecommunications Carriers Eligible for
Universal Service Support, Petition of T-Mobile USA, Inc. for Designation as a Low-Income
Eligible Telecommunications Carrier, et al., Order, 27 FCC Rcd 9495, ¶ 20 (rel. Aug. 16, 2012).
15
D. TruConnect is Financially and Technically Capable
In accordance with 47 C.F.R. § 54.202(a)(4), TruConnect is financially and technically
capable of providing Lifeline-supported services. The Company has been offering
telecommunications service since 1998 and began providing non-Lifeline wireless service in
October 2012, and Lifeline-supported wireless service in May 2013. TruConnect, in
combination with its affiliate Sage d/b/a TruConnect, already successfully provides wireless
services nationwide, including Lifeline services in thirty-nine (39) jurisdictions. TruConnect has
not been subject to ETC revocation proceedings. The Company has operated as a
telecommunications carrier for twenty-five years and has never had to file for bankruptcy
protection, and is supported by the resources of its parent, TSC. TruConnect does not, and does
not intend to, offer exclusively Lifeline-supported services and is therefore not exclusively
dependent on USAC for its revenue. The result of TruConnect’s efforts is that it is fully capable
of honoring all its service obligations to customers and regulatory obligations to state and federal
regulators. Furthermore, the senior management of TruConnect has great depth in the
telecommunications industry and offers extensive telecommunications business technical and
managerial expertise to the Company.29 TruConnect will be providing resold wireless service,
and therefore will also rely upon the managerial and technical expertise of its Underlying
Carriers.
E. Terms and Conditions of Proposed Lifeline Offering
TruConnect can provide all services supported by the universal service program, as
detailed in 47 C.F.R. § 54.101(a), throughout Idaho. TruConnect intends to be a leader in the
prepaid marketplace by offering consumers exceptional value, unlimited voice and competitive

29 See Exhibit 5 for key management bios.
16
broadband usage. TruConnect commits that its Lifeline-supported voice services will meet or
exceed the minimum service standards set forth in 47 C.F.R. § 54.408, including as such
standards are updated going forward. TruConnect’s Lifeline-supported broadband services will
also meet the minimum service standards set forth in 47 C.F.R. § 54.408 for mobile broadband
internet access services, including for service speed and data usage allowance, as such standards
are updated going forward. To the extent TruConnect provides devices for use with Lifeline-
supported broadband service, such devices will meet the equipment requirements set forth in 47
C.F.R. § 54.408(f), and TruConnect will not impose an additional or separate tethering charge for
mobile data usage below the minimum standard.
Attached hereto as Exhibit 6 is a summary table of the Company’s proposed Lifeline
service offering, showing that Lifeline customers will receive unlimited voice minutes, unlimited
text messages, and 4.5 gigabytes (GB) of data per month with full access to the T-Mobile and
Verizon networks at a net cost of $0.00 after application of Lifeline support.30 Lifeline
customers that also elect to receive ACP benefits from TruConnect will receive unlimited talk,
unlimited text, and unlimited data after application of Lifeline and ACP support at a net cost of
$0.00. Customers will be able to purchase additional data as needed. All plans will include
nationwide domestic long-distance at no extra per-minute charge and free international calling to
Canada, Mexico, China, Vietnam, and South Korea. TruConnect will not assess any usage for
access to its free customer services (611). Emergency (911) calls will be free, regardless of
service activation or availability of minutes, and will not count against the customer’s airtime.
The Company’s Lifeline offering will provide feature-rich mobile connectivity for qualifying

30 The current rate plan is based upon the current FCC minimum service standards (“MSS”) and
will change based on the future MSS.
17
subscribers without the burden of credit checks or service contracts. TruConnect’s prepaid
offering will be an attractive alternative for consumers who need the mobility, security, and
convenience of a wireless phone, but who are concerned about usage charges or long-term
contracts.
F. TruConnect Will Comply with the Lifeline Certification and Verification
Requirements
Customers interested in obtaining information on the Lifeline program will be directed to
a toll-free telephone number and to the Company’s website, which will contain information
regarding the Company’s Lifeline service plans, including a description of the Lifeline program
and eligibility criteria. Customers must then apply directly through the National Lifeline
Eligibility Verifier (“National Verifier”), which they may do online or by submitting all required
documentation to the National Verifier by mail. Customers may download a copy of the
application form from the Internet (from the National Verifier’s website) or request that a copy
be mailed to them. TruConnect utilizes the standard Lifeline application forms as required by
FCC rules, and thus complies with the disclosure and information collection requirements in 47
C.F.R. § 54.410(d).31 TruConnect will comply with 47 C.F.R. § 54.410(b) through (g), to the
extent such rules apply to the Company. The Company will notify the subscriber that they must
use their service every thirty (30) days. TruConnect further confirms that it will not activate a
Lifeline service unless or until it has received confirmation from the National Verifier that the
consumer is a qualifying low-income household pursuant to 47 C.F.R. § 54.409, and the
consumer has completed the required eligibility determination and certification requirements of

31 Wireline Competition Bureau Provides Guidance on Universal Forms for the Lifeline
Program, WC Docket No. 11-42, Public Notice, DA 18-161 (rel. Feb. 20, 2018). The standard
Lifeline Application and Recertification Form are available on USAC’s website. See USAC,
Lifeline Forms, http://www.usac.org/li/tools/forms/default.aspx.
18
47 C.F.R. §§ 54.410, 54.404-54.405. Processing of consumers’ applications and determination
of eligibility will be performed by the National Verifier.
G. Prevention of Waste, Fraud and Abuse
The FCC has taken steps to further curb abuse in the Lifeline program by establishing the
National Verifier, which transfers the responsibility of eligibility determination away from
Lifeline providers. TruConnect will rely on the National Verifier to determine initial and
ongoing eligibility of Idaho Lifeline subscribers. The National Verifier queries the National
Lifeline Accountability Database (“NLAD”) for every enrollment to determine whether a
prospective subscriber is currently receiving a Lifeline service from TruConnect or any other
ETC, and whether anyone else living at the prospective subscriber’s residential address is
currently receiving Lifeline service. TruConnect thus complies with the requirements of section
54.404 of the FCC’s rules. In addition, Company personnel emphasize the “one Lifeline service
per household” restriction in their direct sales contacts with potential customers.
Consistent with federal regulations, to the extent the Company offers a Lifeline service
that does not require it to assess and collect a monthly fee from its subscribers, the Company will
not seek USF reimbursement for a subscriber until they have activated the service, by a means
specified by the Company in its terms and conditions, and will de-enroll any subscriber that has
not used the Company’s Lifeline service as set forth in 47 C.F.R. § 54.407(c)(2). An account will
be considered active if the authorized subscriber establishes usage, as “usage” is defined by 47
C.F.R. § 54.407(c)(2), during the specified timeframe, currently a period of thirty (30) days, or
during the notice period set forth in 47 C.F.R. § 54.405(e)(3), currently a period of fifteen (15)
days. In accordance with 47 C.F.R. § 54.405(e)(3), TruConnect will provide the subscriber
advanced notice, using clear, easily understood language, that the subscriber’s failure to use the
Lifeline service within the notice period will result in service termination for non-usage.
19
Customers that have been deactivated may participate in the Company’s Lifeline service in the
future by reapplying and re-establishing eligibility.
H. TruConnect Will Comply with Annual Certification Requirements
TruConnect will rely on the National Verifier for annual recertification of Lifeline
eligibility in accordance with Section 54.410 of the FCC’s Rules.
I. TruConnect Will Comply With Reporting Requirements
TruConnect will provide the Commission a copy of its annual certifications and Lifeline
recertification results pursuant to 47 C.F.R. § 54.416 (i.e., FCC Form 555), as well as a copy of
its annual report filed pursuant to 47 C.F.R. § 54.422 (i.e., FCC Form 481), and will comply with
applicable Commission reporting requirements for Lifeline ETCs.
J. TruConnect Will Comply With Regulations Imposed By The Commission
By this Application, TruConnect hereby asserts its willingness and ability to comply with
the rules and regulations that the Commission may lawfully impose upon the Company’s
provision of service contemplated by this Application. The Company will comply with any
applicable ITSAP rules and regulations, including but not limited to required monthly reporting,
as well as execution of a memorandum of understanding with the Department of Health and
Welfare.32 TruConnect also commits to remitting the required ITSAP funds to the ITSAP
Administrator.
As the Company is not seeking high-cost support for its wireless service, it hereby
requests a waiver of the Commission Rules, Commission Order No. 29841, Section B.1 (two-
year network improvement and maintenance plan based on high-cost support). Because the

32 Idaho Code §§ 56-901, 56-902.
20
Company is not seeking high-cost support, this rule is not applicable and therefore should be
waived.
Upon Commission request, TruConnect is prepared to answer questions or present
additional testimony or other evidence about its services within the state. TruConnect commits
that 100% of federal universal service funds will flow through directly to Lifeline customers.
VI. DESIGNATION OF TRUCONNECT AS AN ETC WOULD PROMOTE THE
PUBLIC INTEREST
One of the principal goals of the Act, as amended by the Telecommunications Act of
1996, is “to secure lower prices and higher quality services for American telecommunications
consumers and encourage the rapid deployment of new telecommunications technologies” to all
citizens, regardless of geographic location or income.33 Designation of TruConnect as an ETC in
Idaho will further that public interest. Whether because of financial constraints, poor credit
history, or intermittent employment, many low-income consumers often lack the countless
choices available to most consumers and thus have yet to reap the full benefits of the intensely
competitive wireless market.
The instant request for ETC designation must be examined in light of the Act’s goal of
providing low-income consumers with access to telecommunications services. The primary
purpose of universal service is to ensure that consumers -- particularly low-income consumers --
receive affordable and comparable telecommunications services. The FCC has in recent years
expanded the Lifeline program to cover broadband services, noting that “Only half of all
households in the lowest income tier subscribe to a broadband service and 43 percent say the
biggest reason for not subscribing is the cost of the service,” and “Of the low income consumers

33 Telecommunications Act of 1996, Pub. L. No. 104-104, 110 Stat. 56.
21
who have subscribed to mobile broadband, over 40 percent have to cancel or suspend their
service due to financial constraints.”34 Given this context, designating TruConnect as an ETC
would significantly benefit low-income consumers eligible for Lifeline services in Idaho -- the
intended beneficiaries of universal service.
A. Advantages of TruConnect’s Service Offering
TruConnect offers a unique, easy to use, competitive, and highly affordable wireless
telecommunications service, which benefits qualified consumers who either have no other
service alternatives or who choose a wireless prepaid solution in lieu of more traditional service.
The public interest benefits of TruConnect’s wireless service include larger calling areas (as
compared to traditional wireline carriers), the convenience and security afforded by mobile
service, and a unlimited amount of voice and generous amount of broadband access included
without cost (after application of the Lifeline support), as well as free access to caller ID, call
waiting, and Voicemail features, and access to 911 services regardless of the number of voice
minutes remaining on the Lifeline consumer’s plan. These no cost to consumer services are an
invaluable resource for cash-strapped consumers, and the prepaid nature of the service also
provides an alternative for “unbanked” consumers.
TruConnect’s Lifeline offerings compare favorably with those of other competitive ETCs,
and provide Lifeline customers with unlimited voice minutes, unlimited text messages, and a
data allotment (meeting the voice and broadband minimum service standards), at no net cost to
the customer after application of Lifeline support. TruConnect’s Lifeline offering will be
provided either over T-Mobile’s 4G LTE network or the Verizon network. TruConnect’s prepaid
wireless service is likely to be an especially attractive option for low-income consumers because

34 See Lifeline Modernization Order, ¶ 2.
22
it alleviates customer concerns regarding hidden costs, varying monthly charges and long-term
contract issues.
In today’s market, consumers, including qualified Lifeline customers, view the portability
and convenience of wireless service not as a luxury, but as a necessity. Mobile service allows
children to reach their parents wherever they may be, allows a person seeking employment
greater ability to be contacted by potential employers, and provides end users with the ability to
contact emergency service providers regardless of location. Mobile service often also serves as a
key bridge in closing the homework gap for students who live in rural areas with limited access
to broadband.
With the comprehensive strength and experience of TruConnect’s management team, the
Company’s proven technology-based business model, and TruConnect’s solid history as a
Lifeline provider, TruConnect is uniquely positioned to meet the needs of Lifeline customers.
Utilizing the Company’s innovative outreach and high integrity enrollment process, and
TruConnect remains committed to careful stewardship of the Lifeline program. Without
question, prepaid wireless services have become essential for low-income customers, providing
them with value for their money, access to emergency services on wireless devices, and a reliable
means of contact for prospective employers, social service agencies or dependents. Providing
TruConnect with the authority necessary to offer discounted Lifeline service to those without
wireless service—or most in danger of losing service altogether—undoubtedly promotes the
public interest.

23
B. The Benefits of Competitive Choice
The FCC has acknowledged the benefits to consumers of being able to choose from
among a variety of telecommunications service providers for more than three decades.35
Increasing customer choice promotes promote competition and innovation, thus spurring other
carriers to target low-income consumers with service offerings tailored to their needs, ultimately
resulting in improved services to consumers. Designation of TruConnect as an ETC will help
ensure that quality services are available at “just, reasonable, and affordable rates” as envisioned
in the Act.36 Introducing TruConnect into the market as an additional wireless ETC provider will
afford low-income Idaho residents a wider choice of providers and available services while
creating a competitive marketplace as ETCs compete for a finite number of Lifeline-eligible
customers. Increasing the competitive marketplace of providers has the potential to effectively
increase the penetration rate and reduce the number of individuals not connected to the PSTN.
C. Impact on the Universal Service Fund
With Lifeline, ETCs only receive support for customers they obtain. The amount of
support available to an eligible subscriber is the same whether the support is given through a
company such as TruConnect or the Incumbent LEC operating in the same service area. The
number of persons eligible for Lifeline support is the same regardless of the number of ETCs;
thus, TruConnect will only increase the amount of USF Lifeline funding in situations where it
obtains Lifeline customers not already enrolled in another ETC’s Lifeline program. By
implementing the safeguards set forth in the Lifeline and Link Up Reform Order and utilizing the
NLAD and National Verifier, the likelihood that TruConnect’s customers are not eligible or are

35 See, e.g., Specialized Common Carrier Services, 29 FCC 2d 870 (1971).
36 See 47 U.S.C. § 254(b)(1).
24
receiving duplicative support either individually or within their household is greatly minimized.
TruConnect’s ability to increase the Lifeline participation rate of qualified low-income
individuals will further the goal of Congress to provide all individuals with affordable access to
telecommunications service, and thus any incremental increases in Lifeline expenditures are far
outweighed by the significant public interest benefits of expanding the availability of affordable
wireless services to low-income consumers.
D. Commission Public Interest Standard
As noted above, when assessing whether designation of an ETC applicant as an ETC
would serve the public interest, the Commission considers whether the applicant will contribute
to the relevant state funds. TruConnect currently contributes to the ITSAP and TRS programs as
required by relevant state law, and will continue to do so after being designated as an ETC. The
Commission also considers whether the applicant is engaged in “cream-skimming.” However,
because TruConnect is seeking ETC designation for the entire state, a cream-skimming analysis
is not required.37
VII. CONCLUSION
Based on the foregoing, designation of TruConnect as an ETC in the State of Idaho
satisfies the requirements of Section 214(e)(2) of the Act and is in the public interest.

37 See Order No. 35126, at 5.
25

WHEREFORE, TruConnect respectfully requests that the Commission promptly
designate TruConnect as an ETC in the State of Idaho for the purpose of participating in the
Lifeline program.
Respectfully submitted,

Debra McGuire Mercer
Michael J. Nemcik
Nelson Mullins Riley & Scarborough LLP
101 Constitution Avenue, NW
Suite 900
Washington, DC 20001
[phone]
[e-mail]

Counsel for TruConnect Communications, Inc.
March 4, 2024

 Admitted to the D.C. Bar under D.C. App. R. 46-A (Emergency Examination Waiver) and
supervised by active D.C. Bar Members.
EXHIBIT 1 
Certification of Nathan Johnson 
CERTIFICATION

STATE OF CALIFORNIA )
)
COUNTY OF LOS ANGELES )

I, Nathan Johnson, the Co-Chief Executive Officer of TruConnect Communications, Inc.
(“TruConnect”) hereby state upon oath and affirmation of belief and personal knowledge that the
matters, facts and statements set forth in the foregoing document are true to the best of
my knowledge and belief; and that TruConnect meets all the statutory and regulatory
requirements for designation as an Eligible Telecommunications Carrier.

Date:
Nathan Johnson, Co-CEO
TruConnect Communications, Inc.
EXHIBIT 2 

FCC-Approved Compliance Plan
and Revised Compliance Plan 
PUBLIC NOTICE
Federal Communications Commission
445 12th St., S.W.
Washington, D.C. 20554
News Media Information 202 / 418-0500
Internet: http://www.fcc.gov
TTY: 1-888-835-5322
DA 12-2063
Release Date: December 26, 2012
WIRELINE COMPETITION BUREAU APPROVES THE COMPLIANCE PLANS OF
AIRVOICE WIRELESS, AMERIMEX COMMUNICATIONS, BLUE JAY WIRELESS,
MILLENNIUM 2000, NEXUS COMMUNICATIONS, PLATINUMTEL COMMUNICATIONS,
SAGE TELECOM, TELRITE AND TELSCAPE COMMUNICATIONS
WC Docket Nos. 09-197 and 11-42
The Wireline Competition Bureau (Bureau) approves the compliance plans of nine carriers:
AirVoice Wireless, LLC (AirVoice); AmeriMex Communications Corp. (AmeriMex); Blue Jay Wireless,
LLC (Blue Jay); Millennium 2000, Inc. (Millennium 2000); Nexus Communications, Inc. (Nexus);
PlatinumTel Communications, LLC (PlatinumTel); Sage Telecom, Inc. (Sage); Telrite Corporation
(Telrite); and Telscape Communications, Inc. d/b/a Telscape Wireless (Telscape). The compliance plans
were filed pursuant to the Lifeline Reform Order as a condition of obtaining forbearance from the
facilities requirement of the Communications Act of 1934, as amended (the Act), for the provision of
Lifeline service.1
The Act provides that in order to be designated as an eligible telecommunications carrier (ETC)
for the purpose of universal service support, a carrier must “offer the services that are supported by
Federal universal service support mechanisms . . . either using its own facilities or a combination of its
own facilities and resale of another carrier’s services . . . .”2 The Commission amended its rules to define
voice telephony as the supported service and removed directory assistance and operator services, among
other things, from the list of supported services.3 As a result of these amendments, many Lifeline-only
ETCs that previously met the facilities requirement by providing operator services, directory assistance or
other previously supported services no longer meet the facilities requirement of the Act.4 In the Lifeline
Reform Order, the Commission found that a grant of blanket forbearance of the facilities requirement,
1 See Lifeline and Link Up Reform and Modernization et al, WC Docket No.11-42 et al., Report and Order and
Further Notice of Proposed Rulemaking, 27 FCC Rcd 6656, 6816-17, paras. 379-380 (2012) (Lifeline Reform
Order). A list of the compliance plans approved through this Public Notice can be found in the Appendix to this
Public Notice.
2 47 U.S.C. § 214(e)(1)(A).
3 See Lifeline Reform Order, 27 FCC Rcd at 6678, para. 47; see also 47 C.F.R. § 54.101(a).
4 See Lifeline Reform Order, 27 FCC Rcd at 6812, para. 366, App. A; Connect America Fund et al, WC Docket 10-
90, Order on Reconsideration, 26 FCC Rcd 17633, 17634-35, para. 4 (2011) (USF/ICC Transformation Order on
Reconsideration). Some ETCs have included language in their compliance plans indicating that they have facilities
or plan to acquire facilities in the future. See, e.g.,Blanket Forbearance Compliance Plan, WC Docket Nos. 09-197
and 11-42, Q Link Wireless, LLC’s Third Amended Compliance Plan at 4 n. 2 (filed July 30, 2012). To the extent
ETCs seek to avail themselves of the conditional forbearance relief established in the Lifeline Reform Order, we
presume they lack facilities to provide the supported service under sections 54.101 and 54.401 of the Commission’s
rules. See 47 C.F.R. §§ 54.101 and 54.401. Such ETCs must comply with the compliance plan approved herein in
each state or territory where they are designated as an ETC, regardless of their claim of facilities for other purposes,
such as eligibility for state universal service funding.
15927
subject to certain public safety and compliance obligations, is appropriate for carriers seeking to provide
Lifeline-only service.5 Therefore, in the Lifeline Reform Order,the Commission conditionally granted
forbearance from the Act’s facilities requirement to all telecommunications carriers seeking Lifeline-only
ETC designation, subject to the following conditions: (1) compliance with certain 911 and enhanced 911
public safety requirements; and (2) Bureau approval of a compliance plan providing specific information
regarding the carrier and its service offerings and outlining the measures the carrier will take to
implement the obligations contained in the Order.6
The Bureau has reviewed the nine plans listed in the Appendix for compliance with the
conditions of the Lifeline Reform Order and now approves those nine compliance plans.7
Filings,including the Compliance Plans identified in the Appendix, and comments are available
for public inspection and copying during regular business hours at the FCC Reference Information
Center, Portals II, 445 12th Street, S.W., Room CY-A257, Washington, D.C. 20554. They may also be
purchased from the Commission’s duplicating contractor, Best Copy and Printing, Inc., Portals II, 445
12th Street, S.W., Room CY-B402, Washington, D.C. 20554, telephone: [phone], fax: (202) 448-
5563, or via email www.bcpiweb.com.
People with Disabilities: To request materials in accessible formats for people with disabilities
(Braille, large print, electronic files, audio format), send an email to [e-mail] or call the
Consumer & Governmental Affairs Bureau at [phone] or TTY [phone].
For further information, please contact Michelle Schaefer, Telecommunications Access Policy
Division, Wireline Competition Bureau at [phone] or TTY [phone].
-FCC -

5 See Lifeline Reform Order, 27 FCC Rcd at 6813-6817, paras. 368-381.
6 See id., 27 FCC Rcd at 6814, 6819, paras. 373, 389. Subsequently, the Bureau provided guidance for carriers
submitting compliance plans pursuant to the Lifeline Reform Order. Wireline Competition Bureau Provides
Guidance for the Submission of Compliance Plans Pursuant to the Lifeline Reform Order, WC Docket Nos. 09-197
and 11-42, Public Notice, 27 FCC Rcd 2186 (Wireline Comp. Bur. 2012).
7 The Commission has not acted on any pending ETC petitions filed by these carriers, and this Public Notice only
approves the compliance plans of the carriers listed above. While these compliance plans contain information on
each carrier’s Lifeline offering, we leave it to the designating authority to determine whether or not the carrier’s
Lifeline offerings are sufficient to serve consumers. See Lifeline Reform Order, 27 FCC Rcd at 6679-80, 6818-19,
paras. 50, 387.
15928
APPENDIX
Petitioner Compliance Plans
As Captioned by Petitioner
Date of Filing Docket
Numbers
AirVoice Wireless, LLC AirVoice Wireless, LLC’s Amended
Compliance Plan
December 7,
2012
09-197; 11-42
AmeriMex
Communications Corp.
AmeriMex Communications Corp.
Revised Compliance Plan
December 6,
2012
09-197; 11-42
Blue Jay Wireless, LLC Blue Jay Wireless, LLC Compliance
Plan
December 19,
2012
09-197; 11-42
Millennium 2000 Inc.Amended Compliance Plan of
Millennium 2000 Inc.
December 18,
2012
09-197; 11-42
Nexus Communications,
Inc.
Third Amended Compliance Plan of
Nexus Communications, Inc.
December 6,
2012
09-197; 11-42
PlatinumTel
Communications, LLC
PlatinumTel Communications LLC’s
Revised Compliance Plan
December 19,
2012
09-197; 11-42
Sage Telecom, Inc.Revised Compliance Plan of Sage
Telecom, Inc.
December 19,
2012
09-197; 11-42
Telrite Corporation Telrite Corporation Compliance Plan December 19,
2012
09-197; 11-42
Telscape
Communications Inc.
d/b/a Telscape Wireless
Revised Compliance Plan of Telscape
Communications, Inc.
December 19,
2012
09-197; 11-42
15929

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CAL I FO RN I A | CO LO R A DO | DI S T R I C T O F CO LU M BI A | FLO R I D A | GE O RG I A | MAR Y L AN D | MAS S A C HU S E T T S
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Jos hua G uyan
T: 2 02 .6 89. 2946
[e-mail]
April 10, 2023
Via ECFS
Jodie Griffin, Division Chief
Telecommunications Access Policy Division
Wireline Competition Bureau
Federal Communications Commission
45 L Street NE
Washington, DC 20554

RE: TruConnect Communications, Inc. Lifeline Compliance Plan;
Federal-State Joint Board on Universal Service, et al., WC Docket Nos.
09-197, 11-42
Dear Ms. Griffin:
On December 26, 2012, Telscape Communications, Inc. (Telscape) received approval
from the Wireline Competition Bureau (Bureau) of its Compliance Plan for its wireless Lifeline
services.1 The Company recently became aware that its approved Compliance Plan did not
reflect its current name TruConnect Communications, Inc. (TruConnect or the Company). In
addition, TruConnect has changed certain of its practices and procedures so that it does not
needlessly duplicate tasks now handled by the National Verifier, National Lifeline
Accountability Database (NLAD) or state administrators, and to reflect current Lifeline rules.
As a courtesy, the Company hereby notifies the Bureau of the following changes.

First, Telscape advises the Bureau that it changed its name to TruConnect through an
amendment to its Certificate of Incorporation. On September 28, 2015, the Secretary of State of
the State of Delaware recognized the amended Certificate of Incorporation and the name change.

1 See generally Wireline Competition Bureau Approves the Compliance Plans of AirVoice
Wireless, AmeriMex Communications, Blue Jay Wireless, Millennium 2000, Nexus
Communications, PlatinumTel Communications, Sage Telecom, Telrite and Telscape
Communications, WC Docket Nos. 09-197, 11-42, Public Notice, DA 12-2063 (rel. Dec. 26,
2012).
TruConnect Communications, Inc. Lifeline Compliance Plan
April 10, 2023
Page 2

Since the Company formally changed its name in 2015, the Company’s filings with the
Commission have indicated that it does business as TruConnect. However, by this letter, the
Company clarifies that its official corporate name for all purposes, including its provision of
Lifelines services, is TruConnect Communications, Inc. The Company requests that the Bureau
update its name in all relevant records.

Second, the Company notifies the Bureau that it has changed certain of its practices and
procedures so that it does not needlessly duplicate tasks now handled by the National Verifier,
NLAD or state administrators, and to reflect current Lifeline rules. Because performing a
practice that is duplicative of those functions now performed by Universal Service
Administrative Company (USAC) and its National Verifier and NLAD database, or state
administrators, is not necessary to achieve compliance, the Company does not view any of these
changes as being “material” changes warranting filing and approval of a revised compliance
plan.2 Processes must evolve to keep pace with changing rules and, when appropriate, to remove
unnecessary burdens from service providers and Lifeline applicants and subscribers.

The Company uses this opportunity to notify the Bureau of changes to its processes so
that compliance functions that were once done by TruConnect, but no longer are necessary, are
no longer part of any perceived compliance plan obligations. The Company also advises that its
processes have been updated to reflect the current regulatory landscape.

Specifically, the following process changes have been made to ensure the Company’s
continued compliance with the Commission’s Lifeline rules:

(a) The Company3 no longer undertakes functions that are performed or are rendered
unnecessary by the National Verifier, NLAD or state administrators. Those functions
include dipping of state databases and collection and review of proof of eligibility for
purposes of (1) determining whether an applicant is currently receiving Lifeline
benefits from another Lifeline service provider; (2) initially certifying Lifeline
applicants’ eligibility; or (3) annually recertifying Lifeline subscribers’ continued
eligibility.

(b) The Company does not make any determinations regarding whether an applicant
meets income-based or program-based eligibility criteria, nor does it make any
determinations regarding whether a Lifeline subscriber has completed the annual re-
certification of eligibility.

2 See Wireline Competition Bureau Reminds Carriers of Eligible Telecommunications Carrier
Designation and Compliance Plan Approval Requirements for Receipt of Federal Lifeline
Universal Service Support, WC Docket Nos. 09-197, 11-42, Public Notice, DA 14-1052 (rel.
July 24, 2014).
3 Reference to the Company encompasses employees, customer service representatives, and
agents.
TruConnect Communications, Inc. Lifeline Compliance Plan
April 10, 2023
Page 3

(c) To the extent that the Company offers a Lifeline service that does not require it to
assess and collect a monthly fee from its subscribers, the Company will not seek
Lifeline support for a subscriber until the subscriber activates the service by a means
specified by the Company in its terms and conditions.4

(d) The Company conducts the enrollment and de-enrollment process consistent with the
requirements of NLAD.5 To the extent that the Company provides Lifeline service in
California, an NLAD opt-out state, it conducts the enrollment and de-enrollment
process consistent with the requirements of the California Third Party
Administrator’s requirements.

(e) The Company provides de-enrollment notices to subscribers after 30 days of non-
usage indicating that failure to use the service within the 15-day notice period will
result in service termination for non-usage.6

(f) The Company has updated its Lifeline service offerings and marketing materials to
reflect current minimum service standards and market realities.7

(g) The Company has replaced its application and certification form and its income
eligibility worksheet with the universal forms as required by the Commission.8

(h) The Company uses the Lifeline Claims System in the NLAD for reimbursement.9

(i) The Company’s underlying carrier has shifted from Sprint to T-Mobile, because of a
merger between those two carriers. The Company’s wireless coverage continues to

4 See 47 CFR § 54.407(c)(1). The Company no longer charges an activation fee to Lifeline
subscribers in all states where it offers Lifeline service, except for California. In California, a
one-time activation fee of $39 is charged to all new or transferred accounts. If a California
LifeLine household is not eligible to receive the $39 activation fee from the California Lifeline
Fund, TruConnect will use its own funds to credit the activation fee.
5 See 47 CFR § 54.404.
6 See 47 CFR § 54.405(e)(3).
7 See 47 CFR § 54.408. The Company’s current Lifeline service offerings are available at
https://www.truconnect.com/lifeline.
8 47 CFR § 54.410(d); Wireline Competition Bureau Provides Guidance on Universal Forms for
the Lifeline Program, WC Docket No. 11-42, Public Notice, DA 18-161 (rel. Feb. 20, 2018).
9 See USAC, Lifeline Claims System (LCS), https://www.usac.org/lifeline/lifeline-claims-
system-lcs/ (last visited June 8, 2022).
TruConnect Communications, Inc. Lifeline Compliance Plan
April 10, 2023
Page 4

include 911/E911 access and 911/E911 compliant handsets compatible with its
underlying carrier’s network.

Pursuant to Section 1.1206(b) of the Commission’s rules, this letter is being filed
electronically. Please feel free to contact me if you have any questions.

Respectfully submitted,

Joshua Guyan
John J. Heitmann
Debra McGuire Mercer

Counsel to TruConnect Communications, Inc.

cc: Nicholas Page
EXHIBIT 3
Coverage Area 
TRUCONNECT COMMUNICATIONS, INC.
IDAHO
SERVICE AREA ZIP CODES

83201
83202
83203
83204
83205
83206
83209
83210
83211
83213
83214
83215
83217
83218
83220
83221
83223
83228
83230
83232
83233
83234
83236
83237
83239
83241
83243
83244
83245
83246
83250
83252
83254
83255
83256
83261
83262
83263
83271
83272
83274
83277
83281
83283
83285
83286
83287
83301
83302
83303
83311
83313
83314
83316
83318
83320
83321
83322
83323
83324
83325
83327
83328
83330
83332
83333
83334
83335
83336
83337
83338
83341
83342
83343
83344
83346
83347
83348
83349
83350
83352
83353
83354
83355
83401
83402
83403
83404
83405
83406
83415
83420
83421
83422
83423
83424
83425
83427
83428
83429
83431
83433
83434
83435
83436
83438
83440
83441
83442
83443
83444
83445
83448
83449
83450
83451
83452
83454
83455
83460
83462
83467
83501
83520
83522
83523
83524
83526
83530
83531
83533
83535
83536
83537
83539
83540
83541
83543
83545
83548
83552
83553
83554
83555
83602
83604
83605
83606
83607
83610
83612
83615
83616
83617
83619
83622
83623
83626
83627
83628
83629
83630
83632
83633
83634
83635
83636
83639
83641
83642
83643
83644
83645
83646
83647
83648
83650
83651
83652
83653
83654
83655
83656
83657
83660
83661
83669
83670
83672
83676
83680
83686
83687
83701
83702
83703
83704
83705
83706
83707
83708
83709
83711
83712
83713
83714
83715
83717
83719
83720
83722
83724
83725
83726
83728
83729
83731
83732
83735
83756
83799
83801
83803
83804
83805
83806
83809
83810
83811
83813
83814
83815
83816
83821
83822
83823
83824
83825
83832
83833
83834
83835
83836
83837
83839
83840
83841
83842
83843
83844
83845
83846
83847
83849
83850
83851
83852
83853
83854
83855
83856
83857
83858
83860
83861
83864
83865
83867
83868
83869
83870
83871
83872
83876
83877
83212
83238
83251
83276
83312
83624
83631
83637
83666
83716
83827
83848

EXHIBIT 4

Sample Advertisements

5 
In-Person Marketing Collateral 
6 
In-Person Marketing Collateral 
2 
Online Advertisement | Social Media
3 
Online Advertisement | Display Ads | Search Engines

Management Bios

EXHIBIT 5
Nathan Johnson
Co-Chief Executive Officer
Nathan is an Owner and Chairman & Co-CEO of TruConnect, where he oversees the
strategic vision and effective governance of the organization. He has co-managed the
overall operations and growth of the business with his brother for the last 15 years. Mr.
Johnson is also a Founder and Managing Partner of Drake Star Partners, a global M&A
Advisory Firm with offices throughout the US and Europe, where he leads efforts on
restructuring and bankruptcy advisory. Prior to Drake Star Partners, Mr. Johnson served as
Director of Overseas Finance for GM’s Treasury Office in NY where he oversaw all
M&A, divestitures and investments in Latin America. Mr. Johnson received his MBA &
MA from the Wharton School & Lauder Institute at the University of Pennsylvania with a
concentration in Finance and Multinational Management. His focus at the Lauder Institute
was a specialized international management program with concentration on fluency in
Spanish and International Studies.
Matthew Johnson
Co-Chief Executive Officer
Matthew led TruConnect to prominence as the 4th largest wireless lifeline company and
fastest growing in the United States with over 600,000 customers nationwide, in his role
as Co-Founder, Board Member, and Co-CEO. With his brother Nathan Johnson, Matthew
built the company with both internal growth and acquisitions including Telscape
Communications, Sage Telecom, and TruConnect Mobile among others. Along with his
focus on TruConnect, Mr. Johnson is also a Managing Partner and Board Member of
Drake Star Partners, a global technology investment bank headquartered in New York with
offices in eight countries. A member of Young Presidents Organization ("YPO") and a two
time finalist for E&Y's Entrepreneur of the Year. Matthew also serves as Chairman for
UCP Wheels for Humanity, a non-profit supplying wheelchairs to disabled children and
young adults globally. Matthew holds an MBA from Northwestern University's Kellogg
School of Management.
Scott Southron
Chief Financial Officer
Scott is a senior executive with over 35 years of experience in investment banking,
financial planning, and strategic business growth. Through a purpose-driven lens, Scott’s
capital funding expertise fortifies TruConnect’s customer acquisition and long-term fiscal
stability goals to achieve profitability. Most recently, he spent nine years at CarrierX,
supporting organizational efforts in serving millions of customers worldwide through a
robust arsenal of connectivity applications. His talent comes from several senior finance
and operations roles, most recognizably at The Walt Disney Company.
Danielle Perry
Chief Compliance Officer
Danielle is TruConnect's Chief Compliance Officer, where she is responsible for leading all
compliance and regulatory related aspects of the organization. Danielle maintains over 20
years of experience in the telecommunications industry, with 15 of those years being
focused on the Lifeline program. She held senior management positions on both operations
and technology teams, in addition to working closely with state and federal agencies on
numerous integration projects. Prior to her tenure at TruConnect, Danielle served as the
Chief Information Officer at Blue Jay Wireless.
Andrew Magaña
Chief Operations Officer
Andrew leads TruConnect's operations including global PMO, sales operations, device
strategy, supply chain, fulfillment, as well as offshore and onshore customer and sales
agent support. Andrew brings over 20 years of experience in strategy, operations, and
revenue management in the high-growth technology and commercial real estate industries.
Prior to TruConnect, Andrew was Divisional President and Regional General Manager at
Postmates, spearheading revenue growth from $175M to $700M and its subsequent
sale/merger with Uber. He was also the General Manager for Uber Ridesharing in
California and Hawaii, achieving 8x business growth in 4 years. Before his technology
career, he worked as an investment professional at the Magellan Group, overseeing the
development of over $300M in commercial real estate. Andrew holds an MBA from
Stanford University Graduate School of Business and a BS from the US Naval Academy.
Lucy Sung
Chief Administrative Officer
Lucy leads TruConnect's legal, customer care, and billing operations teams. She is a
proven executive team leader, with over 30 years of experience in the wireless
telecommunications industry and 15 years of experience managing the operations and
expansion of wireless eligible telecommunications carriers (ETCs). She has held senior
management positions in companies that include AT&T, among others. Lucy holds a BS
in Business Administration.
Kevin Lucier
Chief Technology Officer
Kevin leads TruConnect's engineering, business intelligence (BI), product management and
customer experience teams, coordinating the design and development of products from
concept to reality. With over 25 years of technology leadership experience in ecommerce
and SaaS platforms, Kevin has worked for industry-leading companies such as
BeautyCounter, Sugarfina, Toyota, and Herbalife. He maintains deep knowledge in both
B2B and B2C systems, MLM/Direct Selling, system integration, and is very active in the
Los Angeles start-up community as an advisor and investor. Kevin holds a degree in
Electrical/Electronics Engineering from St. Clair College and University of Windsor.
Ashley Lewis
Chief Product Officer
Ashley is responsible for building TruConnect's product vision and strategy. With over 15
years of experience managing consumer technology products at LA-based startups, Ashley
has led product management teams at Sidecar Health, NEXT Trucking, and Dollar Shave
Club. She was also an early employee at Dog Vacay, where she oversaw the consumer
experience and mobile app teams. Ashley holds two patents for her work in the early days
of native mobile applications. She received an MBA from the UCLA Anderson School of
Management and a BA in Global Studies from UC Santa Barbara.

EXHIBIT 6

Proposed Lifeline Offering

TRUCONNECT WIRELESS IDAHO LIFELINE OFFERING

LIFELINE
PLAN
VOICE TEXT
(SMS)
DATA
(High Speed
- 4G
minimum)
Free
International
Calling
Lifeline
Price
Lifeline Only Unlimited Unlimited 4.5 GB Canada,
Mexico,
China,
Vietnam,
South Korea
$0.00
Tribal
Lifeline Only
Unlimited Unlimited 10 GB Canada,
Mexico,
China,
Vietnam,
South Korea
$0.00

“TOP-UPS” Price
International Top Up (55 Countries) $5
500 MB High Speed Data $5
1 GB High Speed Data $10
3 GB $20
8 GB $30

All packages include:
 Free calls to TruConnect Customer Service
 Free calls to 611 services
 Free calls to 911 emergency services
 Free access to Voicemail, Caller-ID, and Call Waiting features
 Voice minutes may be used for Domestic Long Distance at no extra cost
 Free SIM Card